`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
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`‘ as-D‘Ec-ataas 1a:aaP FROM:
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`TO 1 81215712738388
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`F’: 5
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`existed and worked for its intended puxpose (MPEP 71 5.07||}). The screenshots in
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`Exhibit A further establish possession of the whole invention claimed as it was part of a
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`released product prepared in January 2000 and modified thereafier.
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`The image of Exhibit B illusttates a web based application created at the end of 1999
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`where by the invention is an integral part of the web solution and shown in upper lefi
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`window as “Proprietary F1yOver“‘ - 3D Airfield imagery”.
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`Exhfbit_C shows files confirming that the Invention was introduced in Word Document
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`named “GA Central — Executive Summary.doc" dated 3/20/2000 and Power Point
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`presentation named GA Centra12.ppt dated 5/l 3/2000.
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`Exhibit D is one slide from the PowerPoint presentation listed in Exhibit C. It presem the
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`explanation of the invention, where by the image is a screenshot captured at the end of
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`1999 of the application based on the invention.
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`Exhibit E illustrate the preprooessor subdivides the image into a quad—tree of compressed
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`images The images in the Exhibit E are screenshot captured by running the application
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`based on the patent as oflate 1999.
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`This process can be alternately described as fragmentation of each level in a multi-
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`resolution format to a grid of compressed images. Each ofthesc images are of size 64 by
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`64 pixels, with 16 bits-per-pixel (SKB) packed to 2I<.B using fixed ratio compression as is
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`explained in the patent application This is illustrated in Exhibit F where the images are
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`screenshols from the patent 1999-
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`The viewer (client) uses the patent applicatiorfs method to stream data fiom this
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`compressed image database over natrowband communication. The client included a 3D
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`renderer that provided views of the image frorn arbitrary location with full
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`maneuverability.
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`We assert that the initial implementation of the invention has been completed in I999. It
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`was used to provide a. perspective 3D View of imagery and allowed the user to “fly over”
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`the image interactively. All principles and implementation details disclosed in the patent
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`were in use by this program.
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`The technology is explained in the screenshots and presentation in Exhibit (3 taken by the
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`actual invention as of late 1999.
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`These screenshots illustrate the invention, fully functional, as descnbed in our patent
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`applications and as was implemented and presented from late 1999.
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`Exhibit H is a series of images I, 2, 3, and 4 on a timeline when: 1 is the earliest and 4 is
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`the latest, for the same operator controlled image viewpoint, where the update image
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`parcel is clearly noticeable from image 1 through 2 and 3 to image 4. The update picture
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`parcel is requested by the cl ion! and associated with a request queue. The issuing of said
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`request is over a communications channel. Such picture parcel request queue over
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`communication channel as illustrated in Exhibit G, is shown in the timelinc images in
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`Exhibit H. Whereby, within time (pictures 1 in 4 in ‘Exhibit H), the picture parcel request
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`from the controlled image viewpoint is progressively building the picture parcels from 64
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`by 6y pixels tiles, until the image reached its full resolution as in image 4 of Exhibit G.
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`This is explaining several claims of our patent, including l, 5, 6, 7, 8, 12, 13, l4, l5, l6,
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`I9, 20, and 21. Other claims that have to do with the compression are illustrated in
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`Exhibits E, F, and G. And the same Exhibits E, F, G covers the packet data strearning
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`over communication network as in the related claims. Some of our claims are internal
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`calculations, such as the preprocessing of the image and the compression, which can be
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`illustrated only, with no scrcenshot to show them.
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`The statement of that above establishes that the claimed subject matter has been relied
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`upon and existed prior to Robothazm reference.
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`4.
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`Our company was originally formed as GACentral.oom. Inc. change its name to
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`Flyover Technologies. Inc. in early 2000 and changed it name again to 3‘DVU Inc.
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`relatively recently, so the original materials bear the company names GACentral.oorn and
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`Flyover Technologies.
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`5.
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`In August 2000, we first met with the patent attorney Gerald B. Rosenberg,
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`NewTechLaw, Suite 520, 285 l-lamilton Avenue, Palo Alto, California 94301, to discuss
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`this invention, companion inventions and preparanon of patent applications. Over the
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`succeeding months, Mr. Rosenberg prepared the provisional applications, which was .
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`filed by his office on 27 December 2000.
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`6.
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`The evidence submitted is sufficient to establish a reduction to practice ofthe
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`invention in the US or a NAFTA or WTO member country prior to the effective date of
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`the Robotham reference.
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`7.
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`We hereby declare that all statements made herein of our own knowledge are true
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`and the: all statements made on infomiation and belief are believed to be true; and further
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`that these statements were made with the knowledge that willful false statements and the
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`like so made are punishable by fine or imprisonment, or both, under Section 1001 of Title
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`18 ofthe United States Code and that such willful false statements may jeopardize the
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`validity of the applicalion or any patent issued thereon.
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`_g”
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`‘"76? (XL
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`'‘'-‘*»*‘’|’‘:
`lsaac Levanon
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`Datect December 27, 2005
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`Dated: December 27, 2005
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`\E8-DEC-E885 18: REF’ FROM:
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`Exhibit B
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`Web Site Presentgqon
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`Mavlng orientation
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`Passengers‘ services
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`Exhibit D
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`W
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`The F|yOver “‘
`A 3D Visualization Technology
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`Proprietary 3D 2‘
`engine streaming
`high-resolution
`image (satellite o ;
`aerial) over the
`Internet at about
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`4kIsec. with six
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`degrees of
`freedom
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`EB-DEC-E85 13:23!’ FROM:
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`Exhibit E
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`64 by 64 pixels
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`
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`E38-DEC-E985 1:23P FROM:
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`TD:B121571E37383|ZB
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`Exhibit F
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`rhrJ'?;0UI.-ris apmpnerylnngelstn.-aznfiry tem:mIagydlawmgd:e.mmJ.:rar: of3D
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`'l'heF|yOver'
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`Proprietary 3D engine streaming high-
`rosolutlon Imago (saulllue or aerial" '
`photograph) over the Imomet at about lkls cc.
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`uuumua MB
`With SIX degrees of freedom
`“mm.” Duels
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` Interrupt and (futwo)
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`Wlroloss for Mobile
`Appliances 8: can
`Phones
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`28-DEC-2285 18: 241° FROM:
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